Gifts and Hospitality to Third Parties Policy


Introduction


All members of the University need to be aware that this is a sensitive area where perception is very important. Compliance with this policy will assist members and the University to respond to charges of real or perceived undue influence on the giving of gifts and hospitality to third parties.

Application


This policy applies to all members of the University. 

Purpose


This policy provides guidance to members of the University when giving gifts and hospitality to third parties. It aims to assist members in avoiding any perception of impairment of their objectivity or impartiality.

Policy


1.    All gifts and hospitality with a value over $100 must be recorded on the central Gifts Register

2.    Any deliberate or material breach of this policy may result in disciplinary action, possibly including termination of employment, being taken

Hospitality

3.    Hospitality provided to third parties can only be funded by the University if:

  • there is a clear business purpose, and
  • it is reasonable and appropriate in light of the circumstances, and
  • if it is approved on a one over one basis by a staff member that has not benefited from the hospitality

4.    The University reserves the right to decline reimbursement of hospitality costs which it deems to be non-compliant

5.    For all hospitality paid for by the University, the most senior member of the University in attendance is to pay by expense card or claim a reimbursement

6.    Hospitality costs must be justified on the claimant's expense reimbursement report or expense card reconciliation report

Gifts

7.    Expenditure on gifts must be for a justifiable business purpose of the University, and must be appropriate to the importance of the third party and their contribution to the University

8.    Expenditure on gifts must be appropriate to the circumstances and satisfy at least one of the following tests:

  • Building relationships
  • Building revenue and/or reducing expenditure
  • Reciprocity for gifts received
  • Recognising significant business achievement
  • Furthering the interests of the University

9.    Expenditure must be within the amount budgeted for by the department

10. Gifts must be approved prior to incurring the expenditure as follows:

  • gifts up to $100 only requires approval from a person with the appropriate delegated financial authority
  • gifts with a value between $101 and $500 must have written approval from the relevant SMT member
  • gifts over $500 must have written approval from the Vice-Chancellor or his delegate on the recommendation of an SMT member
  • Managers at level 2 of the University Organisation Structure have the authority to approve gifts that they give to third parties up to the value of $500, and can sub-delegate authority up to 50% of this amount

11. These limits are for the total cost of the gift. It is not acceptable for transactions to be structured in such a way as to attempt to avoid the financial limits set out in this policy

Note: This includes splitting purchases over more than one purchase order, or multiple invoices for a purchase

12. Gifts must not be in the form of cash (except where koha is given) and may not be exchanged by the recipient for cash under any circumstances

13. All purchases are to be made in accordance with the University's usual purchasing procedures

Definitions


The following definitions apply to this policy:

Business purpose includes business discussion, fostering a business relationship, enhancing the reputation of the University (e.g with donors and other stakeholders) or in furtherance of the University’s goals

Gift means a reward, gratuity or other consideration beyond remuneration and reimbursement. It may take the form of a tangible object or a benefit, for example, free use of a corporate box at a sporting event or privileged access to goods or services

Hospitality means catering and entertainment offered to third parties such as customers, donors and official University guests/visitors


Justified means the following details must be recorded on the expense report in order to show that the expense is valid and reasonable:

  • The name of attendees and business relationship
  • The organisation of the third party being entertained
  • Brief explanation of the nature of the discussion

Line manager is the manager that the member reports to who approves the appropriateness of the transaction

Members means those persons who make up the University as set out in section 3(2) of The University of Auckland Act 1961 and includes University employees, students, Council committee members, contractors, sub-contractors and invitees

One over one means a line manager can only approve expenses of their direct reports as per the organisational chart maintained by Human Resources. They cannot approve their own transactions or those of the person that they report to. Nor can they approve expenses of a member at the same level or higher in the organisational chart

University means the University of Auckland including all subsidiaries

Key relevant documents


Include the following:

Document management and control


Owner: Director of Finance
Approved by: Vice Chancellor
Date approved: 26 May 2014
Review date: May 2017